Sanctions and Export Control Alerts: Stay Informed. Stay Compliant.

July 9th, 2026

Authors: John Boscariol and Ljiljana Stanić

In a recent oppression application, CLR Invest Ltd. v. Kondratiev, 2026 ONSC 3832, the Ontario Superior Court dismissed the oppression claim on the merits but, because the parties agreed that the minority shareholder, CLR, should be bought out, ordered the transaction.  The Court, however, held that neither the share transfer nor the payment could proceed until Global Affairs Canada (“GAC”) determined whether CLR would be caught by Canada's Russia sanctions, even though CLR is a Malta entity that is not itself listed. This case illustrates how deemed control concerns under Canadian sanctions law can suspend an otherwise available commercial remedy.

The company, UCT, argued that CLR was deemed to be controlled by RESO, a sanctioned Russian insurer listed under the Special Economic Measures (Russia) Regulations (the “Russia Regulations”), so that transferring CLR's shares or paying it fair value would breach sections 3 and 5 of the Russia Regulations. Under subsection 2.1(2) of the Special Economic Measures Act (“SEMA”), control is deemed to exist on any of three bases - (a) holding 50% or more of shares/votes, (b) the ability to change the composition or powers of the board, or (c) it being reasonable to conclude the person can direct the entity's activities. The Court held that paragraph (c) turns on the ability to direct rather than control actually exercised, consistent with and broader than the de facto control test in Angophora Holdings v. Ovsyankin, 2022 ABKB 711.

CLR is not listed under the Russia Regulations, but RESO and its founders, oligarchs Sergei and Nikolai Sarkisov, are. Measured against GAC's "red flags" guidance, the record showed that CLR's three beneficial owners are current or former senior RESO executives (one still RESO's President, admitting frequent contact with the Sarkisovs), that the Sarkisovs "are known to have funded" the vehicle holding CLR, that owners kept using RESO email to revise transaction documents, and that CLR is a layered Malta/UAE structure interposed between RESO and the investment. CLR countered that RESO holds no direct or indirect interest in it and that its verified ultimate beneficial owners are the three individuals, not RESO.

The Court declined to make a definitive finding, given that both sides had already put the question to GAC, but pointedly refused to ”to give CLR a clean bill of health for sanctions purposes" as there was “considerable evidence creating concern that CLR is or should be caught under SEMA and the Russian Regulations”, which did "not definitively demonstrate" control but engaged "numerous of GAC's red flags". The Court also cited the listing criteria in paragraph 2(g) of the Russia Regulations (senior officials of a paragraph 2(f) entity such as RESO), finding that it "would … capture” all three beneficial owners of CLR.

The takeaway: a counterparty need not be listed to create exposure under Canadian sanctions law. Deemed control under SEMA paragraph 2.1(2)(c) requires no shareholding - only the practical ability to direct. When that is genuinely in issue, courts will defer to GAC and condition any transfer or payment on a GAC ruling or a Ministerial permit.

June 16th, 2026

Authors: John Boscariol and Delaney Stymiest-Losier

On June 16, 2026, Canada announced additional sanctions against Russia under the Special Economic Measures (Russia) Regulations, in connection with the ongoing G7 meetings. The new measures target senior figures and entities supporting Russia's defence‑industrial base and its revenue‑generating strategic sectors, including energy, nuclear services and financial enablers, as well as vessels associated with Russia's so‑called "shadow fleet."

The measures add 34 entities and seven individuals, identified here, and build on Canada's existing Russia sanctions. Of note in this round of designations, Canada has effectively targeted the full spectrum of Russian exchange infrastructure, including the Moscow Exchange (MOEX), the National Mercantile Exchange (NAMEX), the SPB Exchange, SPIMEX, the Saint‑Petersburg Currency Exchange and the Eastern Exchange, together with several Russian banks (Absolut Bank, Zemsky Bank and NBCO Istina) and a crypto‑asset issuer (TengriCoin CJSC). The listings also reach drone and unmanned‑systems manufacturers, a Rosatom nuclear‑energy subsidiary and industrial manufacturers supporting Russia's military‑industrial base.

In addition to these designations, Canada has added 121 vessels to the list of ships subject to prohibitions on docking, passage and the provision of services, intended to further disrupt the maritime networks used to transport and trade Russian oil and other commodities outside the reach of existing sanctions. The newly listed entities also cover the insurance side of the shadow‑fleet crackdown, including marine insurers and protection‑and‑indemnity providers (Soglasie Insurance Company, AMT Insurance and Maritime Mutual Insurance Association (NZ)), alongside ship managers facilitating these networks.

The new designations trigger a broad prohibition on dealings with the listed persons, including direct and indirect facilitation as well as the provision of goods and financial and related services. These prohibitions also extend to non‑listed entities considered to be controlled directly or indirectly by a listed person under Canada's expansive deemed ownership rule. In addition, any property situated in Canada that is owned, held or controlled directly or indirectly by a listed person is now subject to seizure and ascertained forfeiture under Canada's sanctions regime, and listed individuals are inadmissible to Canada.

The amendments also make procedural and technical changes. Most notably, the provisions requiring the Minister of Foreign Affairs to decide de‑listing applications within a prescribed 90‑day period and to provide notice of those decisions without delay have been repealed. The amendments further make targeted adjustments to Canada's trade‑based measures with respect to sourcing from or supplying to Russia, including updates and clarifications to the schedules of prohibited goods.

Although announced on June 16, 2026, the new amendments took effect on June 12, 2026. Companies should immediately update sanctions screening for Russian‑linked counterparties, beneficial owners and control structures, and reassess ongoing contractual, financial or operational exposure.

June 9th, 2026

Authors: John Boscariol and Gajan Sathananthan

Today Canada announced the listing of two individuals and five entities under the Special Economic Measures (Extremist Settler Violence) Regulations (the “Regulations”), its fifth round of sanctions targeting those facilitating extremist settler violence against Palestinian civilians in the West Bank.

The additional individuals and entities listed under the Regulations are:

• Harel David Libi, owner of Libi Construction and Infrastructure Ltd.
• Eliav Libi, Director of Libi Construction and Infrastructure Ltd.
• Regavim, also known as the Regavim Movement
• Coco’s Farm, also known as Coco’s Farm Outpost, Koko’s Farm Outpost and Marom Schmuel Farm Outpost
• Micha’s Farm, also known as Khavat Micha and Micah’s Farm
• Libi Construction and Infrastructure Ltd.
• Nachala

The newly sanctioned parties are now subject to a broad dealings and facilitation prohibition that also applies to non-listed entities deemed to be controlled by them under Canada's expansive deemed ownership rule. Any assets they, or the entities they control, have in Canada are also now subject to expropriation under Canada's seizure and ascertained forfeiture mechanism. Further, the listed individuals are now prohibited from entering Canada.

Although just announced today, the listings came into effect June 4, 2026. More details are available in the backgrounder from Global Affairs Canada, available here: Backgrounder: Canada imposes fifth round of sanctions on facilitators of extremist settler violence against Palestinian civilians in West Bank.

This round of sanctions coincided with a joint statement from Canada, the United Kingdom, Australia, New Zealand, Norway and France, and France separately barred Israeli Finance Minister Bezalel Smotrich from entry. However, while the action is coordinated in timing and intent, the sanctions lists implemented by these countries are not identical. Canada's targets overlap with but do not completely align with actions taken by the UK (which targeted six entities and one individual) or France's entry bans.

For Canadian businesses and financial institutions, it remains important to screen against the Canadian schedule specifically and do so in accordance with Canada's broader deemed ownership and control rules. Cross-jurisdictional screening remains essential.

May 11th, 2026

Authors: John Boscariol and Delaney Stymiest-Losier

On May 11, 2026, Global Affairs Canada announced additional sanctions against Russia under the Special Economic Measures (Russia) Regulations in response to Russia’s unlawful deportation, forced transfer, indoctrination and militarization of Ukrainian children. Global Affairs Canada stated:

“Since Russia first invaded Ukraine in 2014, thousands of Ukrainian children have been illegally deported or forcibly transferred, as well as exposed to indoctrination and militarization by Russian authorities… The unlawful deportation and forced transfer of children constitute a grave breach of international humanitarian law and a profound violation of human rights.”

The measures add 23 individuals and five entities, identified here, involved in these activities and build on Canada’s existing Russia sanctions targeting violations of the rights of Ukrainian children. Those newly listed join Maria Lvova‑Belova, Russia’s Presidential Commissioner for Children’s Rights, who is already designated under Canada’s Russia sanctions, and include additional regional commissioners and government‑affiliated actors responsible for the deportation, transfer, indoctrination and militarization of Ukrainian children.

The new designations trigger a broad prohibition on dealings with the listed persons, including direct and indirect facilitation as well as the provision of financial or related services. These prohibitions also extend to non‑listed entities deemed to be owned or controlled by a listed person under Canada’s expansive deemed‑ownership and control rules. In addition, any property situated in Canada that is owned, held or controlled by a listed person (or entities they control) is now subject to seizure and ascertained forfeiture under Canada’s sanctions regime, and listed individuals are inadmissible to Canada.

Although announced on May 11, 2026, the new listings took effect on May 8, 2026. Canadian companies should immediately update sanctions screening for Russian‑linked counterparties, beneficial owners and control structures, and reassess ongoing contractual, financial or operational exposure, particularly where Russia‑related entities, public‑sector bodies or humanitarian‑adjacent activities may be involved.

May 8th, 2026

Authors: John Boscariol and Delaney Stymiest-Losier

On May 7^th, the US Department of State announced the first designations under the May 1, 2026 Executive Order 14404 (“Imposing Sanctions on Those Responsible for Repression in Cuba and for Threats to United States National Security and Foreign Policy”) (“EO 14404”), a new sanctions authority issued pursuant to the International Emergency Economic Powers Act that expands the US government’s ability to target Cuba‑related activities and establishes a new US secondary sanctions framework relating to Cuba.

This regime introduces new US sanctions risk exposure for any non-US companies, including Canadians, not only when engaging directly with parties designated under EO 14404, but also where they have activities relating to the energy, defense and related materiel, metals and mining, financial services, or security sectors of the Cuban economy. The sanctions also target non-US companies that materially assist, sponsor, or provide “financial, material, or technological support for, or goods or services to or in support of, the Government of Cuba” or any person designated under EO 14404, expanding potential liability beyond the typical US jurisdictional nexus.

The newly designated parties are:

• Moa Nickel S.A. (MNSA) - for operating or having operated in the metals and mining sector of the Cuban economy
• Grupo de Administración Empresarial S.A. (GAESA) - for operating or having operated in the financial services sector of the Cuban economy
• Ania Guillermina Lastres Morera - for being or having been a leader, official, senior executive officer, or member of the board of directors of GAESA

The US State Department notes that "foreign persons that engage in transactions with persons designated pursuant to E.O. 14404 – or that operate in the energy, defense and related materiel, metals and mining, financial services, or security sector of the Cuban economy, as identified in E.O. 14404 – are themselves at risk of sanctions."

They are also indicating that "additional designations can be expected in the following days and weeks".

As Canada is one of Cuba’s largest trading partners and foreign investors, this is especially relevant to Canadian companies and financial institutions. Notably:

• EO 14404 authorizes the imposition of sanctions on non‑US persons, including non-US financial institutions, that conduct or facilitate significant transactions for or on behalf of these designated parties or that are operating in the targeted sectors of the Cuban economy.
• Designation under EO 14404 results in the blocking of property and interests in property within US jurisdiction and prohibitions on dealings by US persons with designated parties.
• In addition, even if not fully blocked under EO 14404, non-US financial institution may be prevented or restricted from accessing US correspondent and payable‑through accounts, which can effectively cut them off from US dollar clearing and the US financial system.

Canadian companies have begun reassessing their activities involving Cuba. See, for example, Sherritt Provides Update on Joint Venture Activities in Cuba.

The implementation of EO 14404 also highlights the need to manage potentially conflicting legal obligations, including in connection with the Foreign Extraterritorial Measures (United States) Order, 1992 issued under Canada’s Foreign Extraterritorial Measures Act. This “blocking order” (i) prohibits Canadian companies from complying with certain US measures relating to the trade embargo of Cuba and (ii) requires notice to the Canadian Attorney General of any instructions, intimations of policy and other communications relating to such US measures received from persons in a position to direct or influence companies’ policies in Canada, creating the potential of legal conflict for Canadian entities navigating both regimes.

April 27th, 2026

Canada has released proposed amendments to its Export Control List, marking a shift in how advanced technologies are regulated for export and transfer abroad.

The proposal would bring a new range of semiconductor‑related technologies and manufacturing equipment under export control, including certain advanced computing chips, assemblies and boards, semiconductor fabrication tools, and specialized inputs used in advanced and additive manufacturing. Existing semiconductor controls have also been reorganized to be more usable in practice.

Notably, the amendments reflect Canada’s increasing implementation of these measures outside of the established multilateral export control regimes such as the Wassenaar Arrangement, aligning with approaches already taken by key allies in response to security risks associated with AI, high‑performance computing, aerospace, and military end‑uses.

A 30‑day public consultation is open until May 25, 2026. Companies operating anywhere in the semiconductor, AI, cloud, or advanced manufacturing ecosystems should expect tighter permitting expectations and should proactively review export classifications, cross‑border technology flows, and compliance strategies.

More details can be found in Canada Gazette, Part I, Volume 160, Number 17: Order Amending the Export Control List.

April 21st, 2026

Global Affairs Canada has just released sector‑specific sanctions guidance for the aerospace and defence industries, underscoring the heightened compliance expectations for companies operating in these highly regulated and geopolitically sensitive sectors.

This guidance comes as the Canadian government is actively encouraging aerospace and defence companies to expand exports beyond the US market, as emphasized in the recently released Defence Industrial Strategy. As firms pursue growth in European, Indo‑Pacific, Asian, Middle East, African, Latin American and other allied markets, GAC’s guidance underscores that sanctions compliance—often alongside export controls—will be central to enabling that diversification, not an obstacle to it.

Key takeaways include:

• Economic sanctions apply alongside export controls: GAC emphasizes that an approved export permit under Canada’s export control regime does not override sanctions prohibitions. In some cases, companies may require both an export permit and a sanctions permit for the same transaction.
• Listed person risk remains front and center: Any transaction involving a listed individual or entity is prohibited without a sanctions permit—even where the counterparty itself is not listed, or where no export controlled goods or tech are involved.
• Expanded due diligence expectations: Companies are encouraged to conduct robust, ongoing due diligence to identify sanctions risks, including attempts to circumvent restrictions through intermediaries, complex ownership structures, or indirect benefits to listed persons.
• Goods, services, and technical assistance all in scope: Restrictions may apply not only to exports and imports of aerospace and defence goods (including dual‑use items), but also to technical assistance, services, and other related support.
• Enforcement risk: Contravening Canadian sanctions is a criminal offence, reinforcing the importance of tailored compliance programs, escalation processes, and regular monitoring of regulatory updates.

For companies in aerospace and defence—particularly those operating internationally or supplying complex technologies—this guidance is a timely reminder that sanctions compliance must be embedded into commercial, procurement, and supply‑chain decision‑making, not treated as an afterthought.

The new GAC guidance can be found here: Canadian sanctions guidance — Aerospace and defence sector.

April 6th, 2026

In late March, Bill C-15, the Budget Implementation Act, 2025, No. 1 was granted royal assent and is now law. This bill amends the Special Economic Measures Act (SEMA) by enacting provisions that now allows the Minister of Finance to make orders directing federal financial institutions to pay to the Receiver General of Canada profits realized from any property in their possession or control that belongs to a person or state that is subject to a sanctions order under SEMA. According to the Budget 2025 document from the Canadian government, this measure is intended to target “windfall profits” from sanctioned property and use these profits to serve public policy purposes. The new amendments also empower the Governor in Council to make regulations requiring that federal financial institutions provide information to the Minister of Finance concerning any such property in their possession or control and information concerning any profits they may have realized from that property. Thus far, no such regulations have been issued. This is a significant step in the Canadian government’s use of sanctions measures to expropriate the earnings from the property of sanctioned persons and the entities they own or control. It also reflects continued integration between Canada’s sanctions and financial‑crimes regimes, with the operational impact to unfold as implementing regulations and guidance are developed.

Bill C-15 also implemented changes to the Export and Import Permits Act (EIPA). These changes expand the potential uses of export and import controls under EIPA, allowing the government to impose controls to ensure Canada’s imports and exports are “consistent with Canada’s economic security interests”. The changes also allows the Canadian government to impose export controls in response to practices of foreign countries that are detrimental to Canada’s economic interests. This provides a new tool for the Canadian government to utilize in the event there are trade actions directed at Canada or impacting Canada’s economic security.

More information on this legislation can be found here.

April 6th, 2026

The Alberta Court of King’s Bench just released a decision that is likely the most substantive sanctions decision yet that we’ve had from Canadian courts: RN Cardium Oil Inc v Loyal Energy (Canada) Operating Ltd, 2026 ABKB 239. The case involved a claim by Cardium Oil, a Canadian subsidiary of the Russian energy company Rosneft, against its Canadian joint-venture partner for failure to make payments owing to Cardium under the joint venture agreement. The joint-venture partner argued that it was unable to make these payments as it was prohibited from doing so based on Cardium being a subsidiary of Rosneft and Canadian sanctions on Russia as imposed under the Special Economic Measures (Russia) Regulations.

Among the key sanctions issues considered by the Court was the control of Rosneft. Though Rosneft itself was not, until recently, listed under Schedule 1 of the Special Economic Measures (Russia) Regulations, Rosneftegaz, which is a significant shareholder in Rosneft, has been listed since February 2023. Based on the information before it, the Court determined that Rosneftegaz controlled Rosneft, including under the control test found in the “deemed ownership rule” in section 2.1 of the Special Economic Measures Act. It also found that Rosneft was controlled by sanctioned persons because several of its board members were listed on Schedule 1 of the Russia sanctions regulations. In doing so, the Court appeared to support the view that in some circumstances sanctioned persons can be aggregated when considering if an entity is de facto controlled under the deemed ownership rule. Ultimately, the Court agreed to summarily dismiss Cardium’s claim based on the finding that it was indirectly controlled by Rosneftegaz.

This case is a significant development in the jurisprudence considering Canadian sanctions. Though it was decided in a civil matter, this decision and its interpretation of the control test may lead GAC to take a more aggressive approach when it is considering control by listed persons.L) system are being notified directly by Global Affairs Canada.

April 6th, 2026

Global Affairs Canada has just issued the new edition of A Guide to Canada’s Export Control List, updating Canada’s export and technology transfer controls to reflect international commitments adopted through January 1, 2026. The revised Guide, referred to as the January 2026 Guide, will enter into force on May 1, 2026, with the current May 2025 version remaining effective until April 30, 2026. Registered users of the New Export Controls On‑Line (NEXCOL) system are being notified directly by Global Affairs Canada.

This update includes a limited number of targeted additions and deletions to controlled items, primarily affecting certain lasers, helium turboexpanders, chemical compounds, and electronic components, while removing controls on specific lower‑resolution analogue‑to‑digital converters and related assemblies. Most other amendments are technical clarifications that do not materially expand the scope of existing controls. The changes impact certain goods and technology classified in Groups 1 (Dual-use items), 4 (Nuclear dual-use items), and 7 (Chemical and biological items) of Canada’s Export Control List. Canadian exporters and brokers should review the updated Guide in advance of May 1, 2026 to confirm classification impacts and ensure permitting and compliance frameworks remain current. The backgrounder and the full January 2026 Guide are available here on Global Affairs Canada’s website.

March 26th, 2026

Today, Canada announced the addition of 100 more vessels in its Russia sanctions list as a result of their  involvement in “shadow fleet” activities, including transporting sanctioned goods and commodities, such as crude oil, to countries around the world, according to the press release from Global Affairs Canada.  Canada has now listed over 600 such ships.

As a result of these listings, these ships are subject to Canada’s vessel‑specific sanctions. These prohibit any person from docking in Canada, or passing through Canadian waters, any ship that is registered in Russia, whose IMO number is listed in Schedule 1.1, or that is otherwise used, leased or chartered, in whole or in part, by or on behalf of or for the benefit of Russia, a person in Russia, or a person listed under the Regulations, unless such docking or passage is necessary to safeguard human life or to ensure navigational safety. In addition, persons in Canada and Canadians outside Canada are prohibited from providing financial or other services to listed vessels.

The amendment to the Special Economic Measures (Russia) Regulations that brings these measures into force can be found here: Regulations Amending the Special Economic Measures (Russia) Regulations (SOR/2014-58). These listings came into force March 25, 2026.

March 26th, 2026

Today, Canada announced expanded sanctions on Iran, listing four entities and five individuals on the basis that they are "engaged in activities that undermine international peace, security or stability in a manner that is consistent with the policies of Iran" and "directly connected to procurement networks that produce and supply technology supporting Iran’s Islamic Revolutionary Guard Corps’ (IRGC) weapons production and transfers to malign actors, including Iran-aligned proxy groups and Russia, which contributes to regional and global instability and fuels armed conflict."

The sanctioned individuals and entities, along with a brief description of their relevant activities, are provided below:

• Chekad Sanat Faraz Asia (also known as Shakad Sanat Asmari), an entity involved in the development and manufacturing of components for Iran’s Shahed series drones
• Saad Sazah Faraz Sharif (also known as Sadid Sazeh Parvaz Sharif and Daria Fanavar Borhan Sharif), an entity involved in the development and manufacturing of components for Iran’s Shahed series drones
• Kimia Part Sivan Company (also known as KIPAS), an entity and drone production arm of the Islamic Revolutionary Guard Corps-Quds Force (IRGC-QF)
• Sarmad Electronic Sepahan Company, an entity involved in the development and manufacturing of electronic and electromechanical components for avionics and drones
• Ehsan Imaninejad, Chief Executive Officer of Saad Sazah Faraz Sharif
• Hadi Zahourian, Chief Executive Officer of Chekad Sanat Faraz Asia
• Mohammad Shahab Khanian, Deputy Chief Executive Officer of Chekad Sanat Faraz Asia
• Ehsan Rahat Varnosfadrani, Chief Scientist and former chief executive officer of Chekad Sanat Faraz Asia
• Rahmatollah Heidari, Managing Director and member of the board of directors of Baharestan Kish Company

There are now over 600 Iranian entities and individuals listed under Canada's Special Economic Measures Act, Sergei Magnitsky Law, and United Nations Act sanctions regimes.

These newly sanctioned parties are now subject to a broad dealings and facilitation prohibition that also applies to non-listed entities deemed to be controlled by them under Canada's expansive deemed ownership rule. Any assets they, or the entities they control, have in Canada are also now subject to expropriation under Canada's seizure and ascertained forfeiture mechanism. Further, the individuals are now prohibited from entering Canada.

The amendment to the Special Economic Measures (Iran) Regulations that brings these measures into force can be found here: Regulations Amending the Special Economic Measures (Iran) Regulations (SOR/2010-165). These listings came into effect March 25, 2026.

More details can be found at the link below. https://www.canada.ca/en/global-affairs/news/2026/03/backgrounder-canada-imposes-additional-sanctions-against-iran.html

Feb 24th, 2026

Canada announced new sanctions against Russia earlier today. These sanctions coincide with the fourth anniversary of the full-scale invasion of Ukraine and, according to the press release from Global Affairs Canada regarding the new measures, are designed to “further increase the economic costs on Russia for its invasion of Ukraine by restricting its energy revenues and financial enablers, including cryptocurrency infrastructure, while degrading Russia’s conventional and hybrid military capabilities, including its artificial intelligence ecosystem and drone production." 

The new measures include:

• listing 53 additional entities, including Rosneft, Tatneft, AFK Sistema, the Skolkovo Foundation, the BitRiver Group, Positive Technologies, and certain Rosatom entities;
• listing 100 additional vessels from Russia’s "shadow fleet";
• listing 21 additional individuals; and
• lowering the price cap for Russian crude oil from US$47.60 to US$44.10 per barrel

The newly sanctioned parties are now subject to a broad dealings and facilitation prohibition that also applies to non-listed entities deemed to be controlled by them under Canada's expansive deemed ownership rule. Any assets they, or the entities they control, have in Canada are also now subject to expropriation under Canada's seizure and ascertained forfeiture mechanism. Further, the listed individuals are now prohibited from entering Canada.

The amendment to the Special Economic Measures (Russia) Regulations that brings these measures into force can be found here: Regulations Amending the Special Economic Measures (Russia) Regulations (SOR/2026-30).Although just announced today, the listings came into effect February 19, 2026.

Feb 24th, 2026

Updated guidance from Global Affairs Canada (GAC) underscores a broader view of control, heightened due‑diligence expectations, and increased enforcement risk across multiple sectors. Shared as a timely reminder of key sanctions developments from the past several months on the fourth anniversary of Russia’s invasion of Ukraine and the announcement of new rounds of related sanctions.

John W. Boscariol, Carmen Francis, Ljiljana Stanic, and Jason Quinn examine:

• Key takeaways from GAC’s new scenarios on ownership, control, and facilitation
• What the new sector‑specific guidance means for financial institutions, universities, and other regulated actors
• Where enforcement, reporting, and due‑diligence expectations are tightening, where uncertainty remains, and more

Read the full article

Feb 18th, 2026

Canada has just announced a significant relaxation of its economic sanctions against Syria, paving the way for Canadian organizations, in both the business and NGO communities, to effectively participate in the rebuilding of the country.

These measures include:

• de-listing 24 entities and one individual “to ease barriers to economic activity and enable transactions with state‑affiliated entities in sectors vital to Syria’s recovery”, including the Commercial Bank of Syria, Syriatel, Syrian Air, the Central Bank of Syria, the Syrian Petroleum Company, as well as others across the energy, financial services, media and communications sectors;
• repealing the general prohibition against providing or acquiring financial or other related services to, from or for the benefit of any person in Syria–a significant barrier to dealings with Syria that had been in place since 2011;
• repealing the prohibitions against making investments in Syria, and importing or sourcing goods from Syria;
• repealing the prohibition against exporting, selling, supplying or shipping any luxury goods to Syria or any person in Syria; and
• introducing new listing criteria “to allow the designation of those involved in gross and systematic human rights violations or in undermining Syria’s peace, security and stability”, and listing six individuals on that basis.

Keep in mind that there are still prohibitions in place regarding a broad range of dealings involving any of the more than 200 listed individuals and entities under the Syria sanctions measures— as well as prohibitions against supplying to, or sourcing from Syria certain goods and technical data relating to chemical weapons.

Although just announced today, these measures came into force on February 13, 2026.

More details can be found here: https://www.canada.ca/en/global-affairs/news/2026/02/backgrounder-amendments-to-sanctions-related-to-syria.html

Feb 17th, 2026

Canada announced additional sanctions on Iran on February 14th, listing an additional seven individuals under the Special Economic Measures (Iran) Regulations who “are linked to Iranian state bodies responsible for intimidation, violence and transnational repression targeting Iranian dissidents and human rights defenders”. The sanctioned individuals, along with a brief description of their relevant activities, are provided below:

1. Naji Ibrahim Sharifi Zindashti, head of the “Zindashti” network, a transnational organized crime network working in collaboration with Iran’s Ministry of Intelligence and Security
2. Reza Hamidiravari, intelligence officer for Iran’s Ministry of Intelligence and Security
3. Mohammed Reza Ansari, a senior official with the Islamic Revolutionary Guard Corps’ Quds Force Unit QF-840
4. Ali Esfanjani, informant, facilitator and associate of the “Zindashti” network
5. Muhammed Abd Al-Razek Kanafani, facilitator and associate of Mohammed Reza Ansari a senior official with IRGC Quds Force Unit QF-840; 
6. Nihat Abdul Kadir Asan, logistical planner, facilitator and associate of the “Zindashti” network
7. Mohammed Reza Naserzadeh, facilitator of and former staff member at the civil registry department of the Iranian consulate in Istanbul, Türkiye

All persons in Canada and Canadians outside Canada are now prohibited from engaging in a broad range of dealings, as well as facilitating such dealings, with these persons. Further, the “deemed ownership rule” under Canadian sanctions law extends these prohibitions to dealings involving non-listed entities that are considered to be controlled by listed persons. This includes (i) non-listed entities in which a listed person holds, directly or indirectly, 50% or more of the shares or ownership interests in the entity or 50% or more of the voting rights in the entity or is able, directly or indirectly, to change the composition or powers of the entity’s board of directors or (ii) circumstances in which it is reasonable to conclude, having regard to all the circumstances, that a listed person is able, directly or indirectly and through any means, to direct the non-listed entity’s activities.

The listings are made effective February 13, 2026. With this announcement, Canada has now sanctioned a total of 478 Iranian individuals and entities through its autonomous sanctions targeting Iran. 

More details can be found here: https://www.canada.ca/en/global-affairs/news/2026/02/backgrounder-canada-imposes-additional-sanctions-against-iran.html. 

Feb 13th, 2026

As the United States continues to take certain steps to relax its economic sanctions against Venezuela following the US military capture of Nicolás Maduro (see for example, today’s announcement from the US Department of the Treasury's Office of Foreign Assets Control on the issuance of new general licenses relating to the exploration and production of oil in Venezuela), Canadian companies and individuals outside of Canada, as well as persons in Canada, should be aware that Canada has not repealed or relaxed any of its sanctions relating to Venezuela. This is especially important for Canadians considering any potential involvement in commercial opportunities relating to the petroleum and other sectors of the Venezuelan economy. These sanctions measures continue to prohibit a broad range of dealings, including facilitation, directly or indirectly involving any of the well over 100 persons who are in or nationals of Venezuela and listed under the Special Economic Measures (Venezuela) Regulations and the Justice for Victims of Corrupt Foreign Officials Regulations, the latter issued under Canada’s Sergei Magnitsky Law. Although only individuals and no entities are currently listed under these measures, the “deemed ownership rule” under Canadian sanctions law extends these prohibitions to dealings involving non-listed entities that are considered to be controlled by listed persons. This includes (i) non-listed entities in which a listed person holds, directly or indirectly, 50% or more of the shares or ownership interests in the entity or 50% or more of the voting rights in the entity or is able, directly or indirectly, to change the composition or powers of the entity’s board of directors or (ii) circumstances which is reasonable to conclude, having regard to all the circumstances, that a listed person is able, directly or indirectly and through any means, to direct the non-listed entity’s activities.

Feb 13th, 2026

We have issued a client alert on Navigating Export Controls in the Clouds: Canada Clarifies Rules on Cloud Storage and Transfers. It provides key highlights on the Canadian government’s long‑awaited guidance (Global Affairs Canada Strategic Export Control Bureau’s Notice to Exporters No. 1159) which significantly impacts the use of cloud services to store or transmit controlled technology, specifically addressing the question of what constitutes an export or transfer under Canadian export controls in this context. The guidance confirms that a transfer occurs for export control purposes where there is a reasonable possibility—more than a remote possibility, but less than the “more likely than not” standard —that a person outside Canada could access or examine the controlled data in a usable form. Server location alone is not determinative: while foreign‑located servers may increase risk, their use not, by itself, establish a transfer. Export permit requirements may arise where foreign access is possible through access rights, decryption keys, or inadequate safeguards, even without evidence of actual access. The same analysis can apply where individuals located outside Canada have a reasonable possibility of access to controlled technology stored in Canada. The guidance also emphasizes a shared‑responsibility model between technology holders and cloud service providers, with technology holders retaining ultimate responsibility for export control compliance while relying on cloud providers’ representations regarding their security practices. For more information, please read the alert.

Dec 15th, 2025

Canada announced the listing of four additional Iranian individuals today under the Special Economic Measures (Iran) Regulations. According to the announcement, these individuals, all Iranian senior officials, have been involved in gross and systematic human rights violations Iran, and have had a significant role in facilitating and directing repressive policies.

The four individuals are:

• Mohsen Karimi
• Ahmad Kadem Seyedoshohada
• Mustafa Mohebbi
• Hassan Akharian

Though announced today, these amendments came into effect on December 12, 2025.

More details are available here: https://www.canada.ca/en/global-affairs/news/2025/12/backgrounder---canada-imposes-further-sanctions-against-iran.html.

Dec 12th, 2025

On December 10, 2025, Canada announced the addition of four new entities to its terrorist list under the Criminal Code: Maniac Murder Cult (MMC), Terrorgram Collective, Islamic State-Mozambique (IS-M), and 764. These are now considered "terrorist groups" under the Criminal Code such that the following is prohibited: engaging in direct or indirect dealings in, or facilitation of transactions in respect of, property owned or controlled by these groups; providing financial or related services in respect of their property or to or for their benefit; and collecting, providing or making available property or financial or other related services that will in whole or in part be used by or benefit these groups. Property owned or controlled by these groups must be frozen and reported to either the RCMP or CSIS. More details here: https://www.canada.ca/en/public-safety-canada/news/2025/12/government-of-canada-lists-four-new-terrorist-entities0.html.

Dec 12th, 2025

On December 5, 2025, following similar steps taken by the United States and the United Kingdom earlier this year, Canada removed Hay’at Tahrir al-Sham (HTS) from its terrorist entity list under the Criminal Code. Syria has also been removed from the List of Foreign State Supporters of Terrorism under the State Immunity Act. More details can be found here https://www.canada.ca/en/global-affairs/news/2025/12/canada-announces-measures-related-to-syria.html. HTS remains on the United Nations sanctions list and is therefore subject to prohibitions under Canada’s Regulations Implementing the United Nations Resolutions on Taliban, ISIL (Da’esh) and Al-Qaida. Further, economic sanctions measures against Syria remain in place under the Special Economic Measures (Syris) Regulations, including a broad prohibition on providing or acquiring financial or related services to, from or for the benefit of any persons in Syria, subject to the General Permit Allowing Specified Activities and Transactions that Are Prohibited Under the Special Economic Measures (Syria) Regulations which allows for certain activities and transactions “aimed at the democratization and stabilization of Syria or the delivery of humanitarian assistance to or within Syria”.

Dec 12th, 2025

Canada’s recently announced 2025 Budget contains a number of important international trade and investment measures and key among them relate to the growing role of the Minister of Finance in economic sanctions, including: a requirement that the Minister of Finance be consulted before foreign financial institutions, central banks, payment service providers, stock exchanges or clearing and settlement systems are added to Canada’s sanctions lists; new powers for the Finance Minister to direct that any profits generated from sanctioned property held by federal financial institutions be remitted to the government as a so-called “Targeted Windfall Profit Charge” is intended “to serve public policy objectives”; and laying the groundwork for establishing a Financial Crimes Agency which would become Canada’s lead enforcement agency for financial crimes – including sanctions enforcement. The 2025 Budget also proposes to amend Canada’s Export and Import Permits Act to allow the government to restrict the importation or exportation of items in response to actions of another country that harm Canada or to create more secure and reliable supply chains. More details here: Budget 2025: Key International Trade and Investment Highlights.

Dec 12th, 2025

Canada has issued long-awaited guidance on application of export and technology transfer controls to cloud computing. In the November 10, 2025 Notice to exporters no 1159 – Guidance on the movement to and storage of controlled technology in the Cloud, Global Affairs Canada’s Strategic Export Controls Bureau clarifies how cloud computing intersects with Canada’s Export and Import Permits Act (EIPA). According to the Bureau, in the cloud context controlled technology is considered to be exported or transferred under the EIPA “if it is sent from Canada and stored in a foreign location in a way that creates a reasonable possibility that a person located outside of Canada would be in a position to examine that technology.” It also notes that “reasonable possibility means more than a mere possibility, but less than the standard of more likely than not. In other words, if there is more than a remote possibility that the controlled technology may be examined by a person outside of Canada in a usable form – either directly or because they hold decryption keys or access rights in a way that creates more than a remote possibility of access – the movement and storage of technology outside of Canada may be considered a “transfer” and require an exporter to apply for a permit.” The notice also addresses topics such as encryption standards, key management practices, shared responsibility between cloud providers and users, and risk mitigation strategies for emerging technologies like AI and machine learning—particularly when these involve controlled technical data or automated processing that could expose sensitive information abroad. It emphasizes that AI-driven systems must be configured to prevent unauthorized foreign access to controlled technology.

Dec 12th, 2025

On November 5, 2025, Global Affairs Canada (“GAC”) published new interpretive guidance for compliance with Canada’s sanctions regimes (the “Updated Guidance”), followed by expanded Frequently Asked Questions (the “FAQs”), last updated November 27, 2025. The Updated Guidance focusses on practical sanctions-compliance scenarios and reiterates GAC’s broad interpretation of the 2023 Deemed Ownership Rule under SEMA and the JVCFOA — including the view that “considerable influence over strategic decision-making” may suffice to establish control, despite this language not appearing in the statutes. GAC has additionally released sector-specific modules for the academic, financial, real estate, and humanitarian sectors, emphasizing enhanced due diligence, indirect-ownership risks, and rising enforcement expectations (including FINTRAC reporting and new requirements effective in 2025). The updated FAQs include new answers addressing how the sanctions regime is being enforced, the application of the Special Economic Measures Act (SEMA) – Russia Regulations and the application of sanctions to academic institutions.